TaxTMI 
TaxTMI 
2024 (3) TMI 686
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....0056/2023, E/52392/2022, E/52416/2022, E/52435/2022, E/51271/2023, E/52393/2022, E/52417/2022, E/52436/2022, E/51272/2023, E/52394/2022, E/52418/2022, E/52437/2022, E/51273/2023, E/52395/2022, E/52420/2022, E/52438/2022, E/51274/2023, E/52396/2022, E/52421/2022, E/52439/2022, E/51275/2023, E/52397/2022, E/52422/2022, E/52440/2022, E/51276/2023, E/52398/2022, E/52423/2022, E/52441/2022, E/51277/2023, E/52399/2022, E/52424/2022, E/52442/2022, E/51729/2023, E/52400/2022, E/52425/2022, E/52443/2022, E/53920/2023, E/52407/2022, E/52426/2022, E/52444/2022, E/53921/2023, E/52408/2022, E/52428/2022, E/52445/2022, E/53922/2023, E/52409/2022, E/52429/2022, E/52470/2022, E/52410/2022, E/52430/2022, E/52471/2022, E/52412/2022, E/52431/2022, E/50028/2023, E/52406/2022, E/52411/2022, E/52427/2022, E/52472/2022, E/51985/2023, E/51739/2023, E/51964/2023, E/52491/2023, E/52873/2023, E/51952/2023, E/51965/2023, E/52492/2023, E/52874/2023, E/51953/2023, E/51966/2023, E/52632/2023, E/52875/2023, E/51954/2023, E/52481/2023, E/52637/2023, E/52876/2023, E/51955/2023, E/52482/2023, E/52638/2023, E/52877/2023, E/51956/2023, E/52483/2023, E/52639/2023, E/54676/2023, E/51957/2023, E/52484/2023, E/52640/2023,....
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....th the help of detailed drawings and designs prepared by the vendors. According to the vendors, the cost incurred by them towards the manufacturing activity includes the development cost incurred in the preparation of the detailed drawings and designs by them. 3. The department, however, believed that the cost of the specifications supplied by Maruti to the vendors free of cost should be included in the assessable value of the final products manufactured by the vendors in terms of rule 6 of the Central Excise Valuation (Determination of Price of Excisable Goods) Rules, 2000 [The 2000 Valuation Rules]. Accordingly, show cause notices were issued to the vendors. The adjudicating authority confirmed the duty demand holding that the cost of the specifications provided by Maruti has to be included in the assessable value of the product manufactured by the vendors and cleared to Maruti. 4. It has, therefore, to be determined whether the notional cost of specifications in the form of drawings and designs supplied free of cost by Maruti to the potential vendors should be included in the assessable value of the parts or components manufactured by the vendors and cleared to Maruti for ....
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....yalty amount under the reverse charge mechanism. 9. In few cases, where alternators are to be manufactured for a new model of vehicle, third parties prepare their own drawings and designs for the necessary tooling/ dies/moulds [Moulds] manufactured and sold to the appellant. The appellant sold the moulds to Maruti and Maruti, in turn, supplied the moulds to the appellant free of cost in terms of rule 4(5)(b) of the CENVAT Credit Rules, 2004 [Credit Rules]. The appellant, thereafter, manufactured the final products with the help of detailed drawings and designs as well as the moulds (wherever required) after amortising the cost of moulds and cleared the final products to Maruti on payment of the applicable central excise duty. 10. The appellant incorporated all costs incurred towards its manufacturing activity, including the development cost incurred towards preparation of the detailed drawings and designs. A copy of the Chartered Accountant certificate showing inclusion of such development cost for preparation of the detailed drawings and designs in the assessable value of the final products for payment of duty has been placed on record by the appellant. 11. According to t....
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.... the amount of lump-sum royalty is includible in such assessable value as the notional cost of specifications provided by Maruti. Accordingly, partial duty demand has been confirmed against the appellant under the extended period of limitation along with interest and penalty has also been imposed equal to the duty demand. The impugned order has dropped the proposal to impose penalty on the employees of Maruti. 15. The facts of the other appeals, except five Excise Appeal No's. 52406, 52411, 52427, 52472 of 2022 and Excise Appeal No. 51985 of 2023, are more or less similar. These five Excise Appeals have been filed by traders to whom show cause notices were also issued on the assumption that they are manufacturers and excise duty has been fastened upon them. One such trader, namely, Minda D-Ten India Pvt. Ltd. (Excise Appeal No. 52411 of 2022), at the time of recording of the statement on 20.12.2018, specifically stated that it was engaged in trading of car infotainment systems and did not undertake manufacturing activities, but still a show cause notice was issued and though this fact that it was not a manufacturer but a trader was also brought to the notice of the adjudicating ....
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....n 4(1)(b) read with Rule 6 of Excise Valuation (Determination of Price of Excisable Good) Rules 2000. ***** 20.5 It has been contended by the Noticees that Sh. Anil Sahani, DGM Finance of M/s MSIL in his five voluntary statements stated that MSIL merely provided its requirement for the components to be manufactured to the vendors as it is a pre-requisite that the component must conform to the drawing/ specification provided by MSIL. I find the contention that the MSIL issues only specifications of the final product, the Internal/child parts are developed and conceptualized by Notices itself does not make any difference as the amount of R&D Incurred by the Noticees on the drawing supplied by MSIL would any way is already accounted for in the assessable value of the final product. However the technical specification supplied by MSIL and cast incurred by MSIL is not included in the moulds/dies manufactured by the vendors. Whether it is shared by MSIL voluntarily or not has no relevance. Whether the vendor is working on the said specification in their own R&D centre to fine tune the said drawing or to design the child parts is of no consequence as the initial specific....
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....lants and made the following submissions : (i) The entire proceedings initiated by the show cause notice which has culminated in the impugned order shows complete callousness and arbitrariness on the part of the department to somehow fasten huge duty liability on the appellant, without considering the correct factual aspects, even though pointed out at the time of investigation itself. Elaborating this submission, learned counsel pointed out that show cause notices were issued even to traders who had not even manufactured the components on the presumption that they were manufacturers and though even before the issuance of the show cause notice and also in reply to the show cause notice this factual position was pointed out but neither the show cause notice or the adjudication order deal with this aspect; (ii) The show cause notice refers to a specific purchase agreement of the year 2007, which has been enclosed as Annexure-19, but this agreement is not relevant to the dispute raised in this appeal; (iii) The provisions of section 4(1)(b) of the Excise Act and rule 6 of the 2000 Valuation Rules are not invokable in the facts and circumstances of the case. ....
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....ules, 2007 [The 2007 Customs Valuation Rules] [corresponding to Rule 9(1)(b) of the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988) and the true scope of the aforesaid clauses (ii) and (iv) of Explanation (1) to rule 6 of the 2000 Valuation Rules can be better understood by analysing the said provisions of the 2007 Customs Valuation Rules; (viii) The decision of the Tribunal in Commissioner of Central Excise, Jamshedpur vs. Tata Motors [2009 (237) ELT 147 (Tri.-Kolkata)] and AVTEC Ltd. vs. CCE, Indore; and AVTEC Ltd. vs. CCE, New Delhi [2017 (358) ELT 700 (Tri.-Del)] relied upon by the department are not applicable to the facts and circumstances of the case; (ix) The extended period of limitation under section 11A(4) of the Excise Act is not invokable in the present case; (x) Penalties are also not imposable under section 11AC of the Excise Act; (xi) The duty demand confirmed in respect of the vendors operating as registered dealers of excisable goods is not sustainable; and (xii) The appellant is entitled to the benefit of cum-duty price. 20. Shri Vikash Agarwal, learned counsel appearing in Excise Appeal No....
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.... considered. 23. The issue that arises for consideration in these appeals is whether the department is justified in demanding the differential central excise duty from the vendors by including the notional cost of specification drawings and deigns supplied free of cost by Maruti in the assessable value of parts or components of motor vehicles manufactured by the appellants and cleared to Maruti. 24. To appreciate this issue, it would be useful to refer to the relevant provisions of the Central Excise Act and the 2000 Valuation Rules. 25. Section 4 of the Central Excise Act deals with 'valuation of excisable goods' for the purposes of charging of duty of excise and the relevant portion is reproduced below: "4. Valuation of excisable goods for purposes of charging of duty of excise- (1) Where under this Act, the duty of excise is chargeable on any excisable goods with reference to their value, then, on each removal of the goods, such value shall- (a) in a case where the goods are sold by assessee, for delivery at the time and place of the removal, the assessee and the buyer of the goods are not related and the price is the sole consideration for th....
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.... use in connection with the production and sale of such goods, to the extent that such value has not been included in the price actually paid or payable, shall be treated to be the amount of money value of additional consideration flowing directly or indirectly from the buyer to the assessee in relation to sale of the goods being valued and aggregated accordingly, namely:- (i) value of materials, components, parts and similar items relatable to such goods; (ii) value of tools, dies, moulds, drawings, blue prints, technical maps and charts and similar items used in the production of such goods; (iii) value of material consumed, including packaging materials, in the production of such goods; (iv) value of engineering, development, art work, design work and plans and sketches undertaken elsewhere than in the factory of production and necessary for the production of such goods." 29. It clearly transpires from the aforesaid provisions that something can be treated as an additional consideration for sale of goods only when there exists a contract of sale or an agreement to sell between the two parties and in terms of such an agreement the buyer pays....
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....ich are incurred by a buyer on behalf of the seller-manufacturer and relieves the seller-manufacturer from incurring such expenses. Thus, the expressions 'drawings, blue prints, technical maps and charts and similar items' mentioned in clause (ii) of Explanation (1), and 'design work and plans and sketches' mentioned in clause (iv) of Explanation (1) can only mean those drawings and designs which a manufacturer would have prepared for use in the manufacture of the product but were prepared by the buyer and supplied to such manufacturer on free of cost or at reduced cost. This is clear from the language used in clauses (ii) and (iv) of Explanation (1) to rule 6 of the 2000 Valuation Rules. It covers drawings which are used in the production of such goods and those designs which are necessary for the production of such goods. 33. The contention of the learned authorized representative appearing for the department, however, is that the drawings/designs supplied by Maruti were only and exclusively instrumental in development of the product by the appellants. Learned authorized representative also pointed out that it is not even the case of the appellant that they could have manufact....
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.... 36. Even if Maruti had to spend some amount for getting these drawings by making payment of royalty to Suzuki Maruti Corporation, Japan, the position would not change as this cannot be said to form an additional consideration for sale of parts or components. It also needs to be noted that these specification drawings provided by Maruti to the potential vendors cannot be said to be used in the production of the components or necessary for the production of the components in terms of rule 6 of the 2000 Valuation Rules. Thus, clauses (ii) or (iv) to Explanation (1) of rule 6 of the 2007 Valuation Rules cannot be invoked in the facts and circumstances of the present case. 37. At this stage, it would also be appropriate to compare Explanation (1) to rule 6 of the 2000 Valuation Rules to an analogous rule 10(1)(b) of the 2007 Customs Valuation Rules. This rule 10(1)(b) is reproduced below: "10. Cost and services - (1) In determining the transaction value, there shall be added to the price actually paid or payable for the imported goods- (a) ***** (b) the value, apportioned as appropriate, of the following goods and services whether supplied directly or indi....
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....the machine - that is, of telling the manufacturer the specifications of what is being ordered. Only if the engineering or drawing goes further should it be deemed to be a part of the production process. Up to that point, each specification and instruction is more appropriately regarded as an added requirement or burden imposed upon the manufacturer, rather than a form of assistance. Otherwise expressed, these are buying costs, not costs of the seller from which he is being relieved by the buyer." (emphasis supplied) 40. The Tribunal in Mangalore Refinery & Petrochemicals Ltd. vs. C.C., Mangalore [2014 (313) E.L.T. 353 (Tri. - Bang.)] also held that there is a distinction between mere specifications and detailed engineering drawing. It is only the latter which is covered under rule 9(1)(b)(iv) of the Customs Valuation (Determination of Price of Imported Goods) Rules, 1988 (which is now rule 10(1)(b)(iv) of the 2007 Customs Valuation Rules). The relevant portion of the decision of the Tribunal is reproduced below: "9.3 When a person buys a product available, off-the-shelf, he need not be concerned with the Engineering Design and services which have gone into the manuf....
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....iled inputs for undertaking manufacture. The other merely indicates the lay out, relative size etc. From the size specifications alone construction of engineering equipment is not feasible. "Telling the manufacturer, the specification of what is being ordered" is only in the nature of buyers' assist. Cost incurred towards buyers' assist cannot be included in the value of imported goods. (d) When the technical know-how and engineering services are not related to the equipment designs but are for the purpose of preparation of tender documents and for recommending for selection of the equipments the cost of the same cannot be included in the value of imported goods." (emphasis supplied) 41. The same view was taken by the Tribunal in G.E. Plastics India Ltd. vs. Commissioner of Customs, Mumbai-I [2004 (169) E.L.T. 46 (Tri. - Del.)] and the observations are as follows: "6. It is the Revenue's case that the process diagram and equipment specification supplied by M/s. GE Plastics India Pvt. Ltd. BV, Netherlands were vital for the preparation of detailed engineering drawings for the manufacture of the imported equipment and that is sufficient to attract the provisio....
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.... vendors for 'generator assembly' for manufacture of alternators. It bears the endorsement 'THIS IS A DESIGN SPECIFICATIONS DRAWING'. It is also mentioned that 'this drawing specifies the conditions that Suzuki requires from suppliers on shape, dimensions, functions, qualities etc., part(s)/assembly' and 'suppliers shall be responsible for designing the part(s)/assembly to meet Suzuki's requirements shown in the drawing without infringing upon any third party's intellectual property rights and submit the drawing'. 44. It is apparent from the aforesaid that the specifications provided by the Maruti were merely layout or dimensions of the desired parts or components. The appellant prepared detailed drawings and designs for alternator assembly in line with the specifications provided by Maruti. The designs prepared by the appellant contain details of various elements to be used in the manufacture of alternator assembly. It contains 23 sub-components required for manufacturing alternator assembly, which is not even referred to in the specification drawings provided by Maruti to the appellant. 45. The Letter of Intent issued to the appellant also states that: "We are plea....
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....nd designs supplied free of cost by Maruti to the vendors cannot be included in the assessable value of the parts and components manufactured by vendors and cleared to Maruti for the purpose of payment of central excise duty. 51. In this view of the matter, it would not be necessary to examine the contention that has been raised by the learned counsel for the appellants that the extended period of limitation could not have been invoked in the facts and circumstances of the present case. 52. Thus, for all the reasons stated above, all the Excise Appeals have to be allowed. The five Excise Appeals filed by traders have also to be allowed for the additional reason that in any view of the matter central excise duty could not have been levied on them. 53. In the result, the impugned orders dated 29.07.2022, 25.08.2022, 30.11.2022, 30.12.2022, 10.01.2023, 23.02.2023, 30.03.2023 and 28.04.2023 passed by the adjudicating authority deserve to be set aside and are set aside. All the Excise Appeals are, accordingly, allowed. (Order Pronounced on 12.03.2024) Cause list sl. no. Appeal No. Duty demand confirmed (in Rs.) Show Cause N....
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....ond 5 years) 1,190 21 E/52296/2022 22 E/52297/2022 4,07,970 25.04.2019 April 2014 to June 2017 Upto March 2017 12,859 23 E/52298/2022 6,61,105 06.08.2019 April 2014 to June 2017 Upto June 2017 (April 2014 to July 2014 is beyond 5 years) - 24 E/52299/2022 80 E/50004/2023 56,118 24.05.2019 April 2014 to June 2017 Upto April 2017 (April 2014 is beyond 5 years) 4,621 Order dated 25.08.2022 25 E/52389/2022 13,45,531 13.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 1,17,360 26 E/52390/2022 15,39,175 12.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 1,43,180 27 E/52391/2022 49,41,104 05.03.2019 November 2013 to June 2017 Up to January 2017 (No....
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....014 is beyond five years) 7,360 42 E/52411/2022 6,28,075 12.02.2019 December 2013 to June 2017 Not Applicable Not Applicable 43 E/52412/2022 22,63,904 21.06.2019 April 2014 to June 2017 Up to May 2017 (April 2014 to May 2014 is beyond five years) 54,860 44 E/52413/2022 13,59,227 21.05.2019 April 2014 to June 2017 Up to April 2017 (April 2014 is beyond five years) 29,500 45 E/52414/2022 2,57,261 07.05.2019 April 2014 to June 2017 Up to March 2017 12,035 46 E/52415/2022 11,83,422 15.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 48,615 47 E/52416/2022 15,53,094 03.04.2019 April 2013 to June 2017 Up to February 2017 (April 2013 to February 2014 is beyond five years) 82,487 48 E/52417/2022 11,50,215 04.06.2019 April 2014 to June 2017 Up to April 2017 (April 2014 is beyond five years) 28,716 49 ....
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....e barred (April 2014 to November 2014 is beyond five years) Entirely time barred 63 E/52432/2022 19,69,949 10.01.2020 April 2014 to June 2017 Entirely time barred (April 2014 to November 2014 is beyond five years) Entirely time barred 64 E/52433/2022 7,74,844 12.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 63,201 65 E/52434/2022 5,74,808 18.03.2019 November 2013 to June 2017 Up to February 2017 (November 2013 to February 2014 is beyond five years) 29,238 66 E/52435/2022 2,97,464 18.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 36,883 67 E/52436/2022 7,27,679 14.03.2019 November 2013 to June 2017 Up to February 2017 (November 2013 to February 2014 is beyond five years) 26,999 68 E/52437/2022 35,46,582 18.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 2,82,041....
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.... January 2014 is beyond five years) 1,17,271 84 E/50056/2023 3,11,032 25.04.2019 November 2013 to June 2017 Up to March 2017 (November 2013 to March 2014 is beyond five years) 9,740 85 E/51271/2023 5,59,904 04.04.2019 November 2013 to June 2017 Up to February 2017 (November 2013 to February 2014 is beyond five years) 37,365 86 E/51272/2023 3,03,973 14.02.2019 November 2013 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 22,190 87 E/51273/2023 6,59,513 07.05.2019 April 2014 to June 2017 Up to March 2017 25,346 88 E/51274/2023 81,14,928 21.05.2019 November 2013 to June 2017 Up to April 2017 (November 2013 to April 2014 is beyond five years) 2,39,410 89 E/51275/2023 2,69,740 11.06.2019 April 2014 to June 2017 Up to May 2017 (April 2014 to May 2014 is beyond five years) 28,746 90 E/51276/2023 16,14,111 14.02.2019 November 2013 to Ju....
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.....2019 March 2014 to June 2017 Up to February 2017 1,05,865 103 E/51961/2023 2,05,580 24.05.2019 May 2014 to June 2017 Up to April 2017 1,121 104 E/51962/2023 16,34,346 23.05.2019 May 2014 to June 2017 Up to April 2017 52,290 105 E/51963/2023 2,04,36,353 (2,00,63,450 + 3,73,203) 01.02.2019 January 2014 to June 2017 Up to December 2016 19,15,854 106 E/51964/2023 55,61,303 (55,25,479 + 35,824) 13.03.2019 March 2014 to June 2017 Up to February 2017 3,08,104 107 E/51965/2023 2,81,518 (2,76,247 + 5,271) 20.03.2019 February 2014 to June 2017 Up to February 2017 14,832 108 E/51966/2023 74,27,270 (73,07,155 + 1,20,115) 06.02.2019 January 2014 to June 2017 Up to December 2016 7,30,472 110 E/52481/2023 62,646 (62,601 + 45) 21.02.2019 February 2014 to June 2017 Up to January 2017 6,964 111 E/52482/2023 3,24,015 11.04.2019 April 2014 to June 2017 Up to March 2017 16,302 ....
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.... 128 E/52642/2023 1,06,21,306 (1,04,40,683 + 1,80,623) 01.02.2019 January 201 to June 2017 Up to January 2017 (November 2013 to January 2014 is beyond five years) 8,18,308 129 E/52643/2023 17,89,486 (17,77,772 + 11,714) 12.03.2019 March 2014 to June 2017 Up to February 2017 82,656 130 E/52644/2023 4,53,967 (4,53,420 + 547) 14.03.2019 March 2014 to June 2017 Up to February 2017 43,110 131 E/52645/2023 17,57,789 22.08.2019 August 2014 to June 2017 Entirely time barred Entirely time barred 132 E/52872/2023 7,57,468 23.08.2019 August 2014 to June 2017 Entirely time barred Entirely time barred 134 E/52874/2023 1,28,005 09.05.2019 April 2014 to June 2017 Up to March 2017 12,414 135 E/52875/2023 7,82,092 19.08.2019 August 2014 to June 2017 Entirely time barred Entirely time barred 136 E/52876/2023 14,83,153 (14,66,710 + 16,443) 13.02.2019 February 2014 to June 2017 Up to....
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.... E/MISC/50541/ 2023 E/53897/2023 54,64,448 (54,01,970 + 62,478) 28.01.2019 January 2014 to June 2017 Up to December 2016 6,18,855 149 E/53898/2023 31,16,816 (30,84,711 + 32,105) 20.02.2019 February 2014 to June 2017 Up to January 2017 2,75,876 150 E/53899/2023 36,84,119 (36,55,337 + 28,782) 14.02.2019 February 2014 to June 2017 Up to January 2017 3,14,014 151 E/53900/2023 15,56,095 16.08.2019 August 2014 to June 2017 Entirely time barred Entirely time barred 152 E/53901/2023 22,58,708 (22,42,116 + 16,592) 28.03.2019 March 2014 to June 2017 Up to February 2017 1,26,103 153 E/53902/2023 7,58,596 14.05.2019 May 2014 to June 2017 Up to April 2017 17,733 154 E/53903/2023 8,80,309 07.05.2019 April 2014 to June 2017 Up to March 2017 72,000 155 E/53904/2023 14,78,830 20.04.2019 April 2014 to June 2017 Up to March 2017 77,161 156 E/53905/2023 5,88,873 (5,78,697 + 10,176) 08.02....
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.... Up to January 2017 62,350 Order dated 10.01.2023 204 E/54767/2023 205 E/54799/2023 Order dated 23.02.2023 177 E/54985/2023 1,18,091 16.12.2019 December 2014 to June 2017 Entirely time barred Entirely time barred 180 E/54994/2023 3,94,450 (3,90,239 + 4,211) 05.03.2019 February 2014 to June 2017 Up to January 2017 29,386 181 E/54995/2023 1,83,478 (1,81,069 + 2,409) 15.06.2019 February 2014 to June 2017 Up to May 2017 6,152 182 E/54996/2023 8,06,854 08.05.2019 May 2014 to June 2017 Up to March 2017 58,885 183 E/54997/2023 6,34,806 20.05.2019 May 2014 to June 2017 Up to April 2017 17,917 184 E/54998/2023 8,44,865 (8,35,998 + 8,867) 14.02.2019 February 2014 to June 2017 Up to January 2017 63,095 185 E/54999/2023 10,95,471 07.05.2019 April 2014 to June 2017 Up to March 2017 48,74....